California Asphalt Magazine – 2022 Environmental Issue

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INSIDE: Focus on community air monitoring FACT SHEET: Environmental Product Declarations (EPDs) CalAPA engages the South Coast Air Quality Management District on new regulations

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Publisher’s Letter Recently I had the opportunity to attend the annual Mid-Year Meeting put on by the National Asphalt Pavement Association in our home state of California. The weather in Santa Barbara couldn’t have been more perfect, and it was great to see so many CalAPA members in attendance in support of our industry and our national partners. Despite the sunny weather, however, it was clear that storm clouds are on the horizon. For those of us who live and work in California, we know all about the very difficult regulatory climate for businesses trying to respond to concerns important to our fellow Californians, whether it be on the economic, social, environmental or quality-of-life front. In the case of asphalt, as most of the readers of this publication know, it is manufactured locally with local workers who live in the communities they serve. And because asphalt must be placed on a project soon after it is manufactured, it is important that all regions of our state have access to raw materials and local manufacturing facilities nearby to serve the needs of public and private project owners. Project designers know that asphalt provides superior performance and value for their pavement dollar, and also has many other positive sustainable attributes. That’s why asphalt covers 95% of paved surfaces in the Golden State. What was striking about this year’s NAPA Mid-Year conference, however, was the high degree of interest in environmental and climate-change topics by representatives from other states. Perhaps it is related to “The Road Forward,” the asphalt industry’s bold net-zero climate initiative that was unveiled earlier this year. Maybe it was the drumbeat of news stories about the climate emergency and the push by elected officials and regulators to show progress on this front. Or it just could be that California is well-known across the country for pioneering many innovations in safety, emissions and equity that are being emulated by others. Regardless of the reason, the meeting of the Western States, known formally as the NAPA Advisory Council West/Pacific Region, was packed, as were other environmental-related sessions held during the conference. It was clear to me that our industry is responding to these challenges by putting our best minds and our best efforts into developing practical solutions. There is clearly a hunger for knowledge about these issues. This special edition of California Asphalt magazine represents one of the many ways CalAPA is supporting this effort. The content is curated by our highly effective Environmental Committee, which runs point for our association on a myriad of issues that could be ruinous for our industry without our active engagement. This month’s issue features important “deep dive” articles about constantly changing air quality regulations, a recap of our association’s impressive webinar series about the future of powering our plants and our fleets, exhaustively researched fact sheets, and other topics that are designed to increase awareness for our members, help them manage risk, and prepare for changes that are on the horizon. Even with storm clouds clearly in sight, CalAPA is like the sturdy umbrella that helps our industry weather the changes and continue to be successful to serve our fellow Californians.


Jordan Reed George Reed, Inc.


California Asphalt Magazine • 2022 Environmental Issue

THE RIGHT PEOPLE. THE RIGHT EQUIPMENT. RIGHT AWAY. It takes grit and determination to keep our country moving ahead. It’s why Coastline’s only goal is helping you make progress every day. To finish jobs on time and on budget. Because nothing is more important to us than your project. Whether you’re a one man operation or a crew of hundreds, we provide reliable equipment, precision technology and on-site emergency service. Everything to empower you from start to finish.


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Contents Volume 25, Issue 4

4 8

Publisher’s Letter What’s next? CalAPA webinars on the future of powering asphalt plants and fleets attempt to answer the question


In their own words: Excerpts from the future of powering asphalt plants and fleets webinars


Questions & Answers “The Future of Powering Asphalt Plants in California” webinar


FACT SHEET: Environmental Product Declarations (EPDs)


FACT SHEET: Information about asphalt plants, neighborhoods and the environment


CalAPA engages the South Coast Air Quality Management District on proposed rules covering ‘fugitive dust’ from large roadway construction projects


‘Hyperlocal’ air monitoring adds another layer of complexity, potential for confusion in the air quality debate


Implementation of NOx limits on Asphalt Dryers through Rule 1147.1 begins in South Coast AQMD

Page 12

Page 18

On the Cover: A truck receives a load of asphalt. Air quality regulations with regard to asphalt plants and on-road and off-road vehicles continue to change, which is an ongoing challenge for the asphalt industry. Photo by Russell W. Snyder.

Page 28


P.O. Box 981300 • West Sacramento • CA 95798 (Mailing Address) 1550 Harbor Blvd., Suite 211 • West Sacramento • CA 95691 • (916) 791-5044 Russell W. Snyder, CAE, Brandon M. Milar, P.E., Sophie You, Jackie Henry, Jordan Reed, George Reed, Inc. Construction Marketing Services, LLC • (909) 772-3121 P.O. Box 892977 • Temecula • CA 92589 Aldo Myftari Russell W. Snyder, CAE, CalAPA, Scott D. Cohen, P.E., C.I.H., Sespe and Scott Taylor, Taylor Environmental Services, Inc. Kerry Hoover, CMS, (909) 772-3121

Copyright © 2022 – All Rights Reserved. No portion of this publication may be reused in any form without prior permission of the California Asphalt Pavement Association. California Asphalt is the official publication of the California Asphalt Pavement Association. This bimonthly magazine distributes to members of the California Asphalt Pavem­­ ent Association; contractors; construction material producers; Federal, State and Local Government Officials; and others interested in asphalt pavements in California and gaining exclusive insight about the issues, trends and people that are shaping the future of the industry.


California Asphalt Magazine • 2022 Environmental Issue

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WHAT’S NEXT? CalAPA webinars

on the future of powering asphalt plants and fleets attempt to answer the question By Russell W. Snyder


key take-away from an ambitious CalAPA webinar series about the future of powering asphalt plants and fleets: It’s not any one regulation that presents a challenge for the asphalt industry in California, it is all of them, and the fact that they are constantly changing. Another key take-away: the state agency responsible for ensuring reliable power for the Golden State and the agency regulating air pollution seem to be operating in parallel universes, which could spell trouble for the asphalt pavement industry in the years ahead. The California Asphalt Pavement Association (CalAPA), the only statewide construction trade association that focuses exclusively on asphalt pavements, assembled a wide range of experts from the public and private sector for a pair of educational webinars that were broadcast live in June, with recordings available for later viewing. The CalAPA Environmental Committee spearheaded the educational effort. Judging by the robust attendance and high marks from participants, the webinar series brought much-needed clarity and context to a maddeningly complex topic. “The Future of Powering Asphalt Plants in California” broadcast June 20 featured experts from the California Energy Commission, the California Air Resources Board (CARB), utilities, asphalt plant manufacturers, alternate fuel authorities and other experts. The 8

session was followed up by “The Future of Powering Asphalt Fleets in California,” which also featured an impressive array of experts, including representatives from CARB, equipment manufacturers, consultants and others. Each session was introduced by CalAPA Environmental Committee CoChairs Scott Taylor with Taylor Environmental Services and Scott Cohen with Sespe Consulting, a Trinity Company. Recordings of both sessions, as well as copies of PowerPoint presentations referenced during the programs, are available via the CalAPA on-line “Knowledge Center.” The association made the sessions free and open to anyone in keeping with the association’s educational mission. Webinar attendees came from across California and other states, providing an indication of the high degree of interest in the topics and California’s bellwether status with regard to environmental regulations. “The end of this has not been written on all of these items we have been talking about,” said Taylor following the webinar series. The longtime CalAPA Environmental Committee leader added, “This is the beginning of the discussion on many of these topics. The webinars are one way for people to get information and think about and prepare for what will eventually happen. As we heard from the speakers, there are a variety of challenges we will need to overcome to get there.”

CalAPA Director of Technical Services Brandon Milar kicked off the first “plants” session with a presentation on “The Road Forward,” the asphalt industry’s national initiative to achieve a net-zero carbon footprint by 2035. The multi-pronged initiative was unveiled in January and incorporates many goals and strategies, including conducting research to fill in knowledge gaps and deploying new technology to meet the ambitious climate target. Emissions from asphalt plants and fleets are at the center of the initiative. The subsequent expert presenters, representing a wide range of perspectives, received high marks from webinar attendees as they covered the state of technology and regulations today, what is expected in the near term and what may be over the horizon. The live polls and opportunities for questions made the webinars interactive and ensured that information was relevant to the audience. Said one attendee, a representative of the California Air Resources Board: "The polls you conducted at the beginning of the June 27 session were extremely helpful in identifying the audience and their comfort level with the upcoming regulations. The session I listened in on was very professionally facilitated with a slight bit of humor to keep participants engaged." Indeed, those “live” polls revealed the high level of worry for webinar attendees. In the June 20 “Plants”

California Asphalt Magazine • 2022 Environmental Issue

webinar, participants were asked to rate their level of anxiety with regard to regulatory issues. Of those who responded, 23% said they were “Extremely Anxious” while 54% said they were “Somewhat Anxious.” There were 21% of respondents who identified with the choice “I’m Cool” while only 2% said “I’ve Got This.” Asked to rank various aspects of environmental and regulatory issues, 21% put “Constant Change” at the top of the list, 16% chose “Complexity,” 9% chose “Community Pressure” while 7% selected “Cost.” A whopping 47% chose “All of the Above.” In the June 27 “Fleets” webinar, 17% said they were “extremely anxious” about the regulatory environment, and 67% said they were somewhat anxious. Only 13% agreed with the statement “I’m Cool” and a scant 4% chose “I’ve Got This.” Asked to rank what worries them the most, the “Fleets” participants said “Complexity” (32%),closely followed by “Cost” (27%) and “Constant Change” (27%). “Community Pressure” came in at 14%. Several of the presenters at both webinars incorporated references to the live polls in their remarks. “The anxiety that fleet managers have from the complexity of fleet regulations may not necessarily come from any particular regulation, it is the fact that there are all these regulations laid on top of each other,”said Drew Delaney with Associates Environmental during his presentation on best practices for fleet management. “I think that is a huge source of the complexity anxiety, and perhaps the cost as well because a lot of these regulations have different implementations that cost a fleet, from one year to the next, a considerable amount of money, and then maybe a lot less the next year, and maybe a lot more the year after that, so it’s not really a flat expense curve for every single

one of these regulations that are piled on top of each other.” The specific, actionable information in the webinars resonated with webinar attendees. In post-webinar surveys, one participant said they liked the “actionable ideas from industry speakers” and “some possible solutions to upcoming emissions reductions.” One “Plants” survey respondent said, “The regulators need to focus on what producers can cost-effectively do to improve their compliance. What is working?” A “Fleets” survey respondent said they appreciated “the chance to speak with CARB about massive new regulations,” while another respondents said they appreciated the “clarification on requirements, deadline and exceptions.” Even the presenters, who are experts in the field, were awe-struck about the complexity of the regulatory environment in California. “I’m still confused by the rules and the regulations, what is actually set in stone, what is proposed, and what is not,” said Zach Lawson with CalAPA member Opal Fuels, a subject-matter expert who attempted to demystify different ways to power fleets, including CNG/RGG, diesel, electric and hydrogen. “I think having more of those

California Asphalt Magazine • Environmental Issue

discussions is valuable for everybody in the industry, and having those people actually speak and be able to ask questions in a live forum, whether you get a clear answer or not.” He related with the anxiety expressed by many webinar participants, and he said he hears it often from fleet managers: “What do I plan for? Do I try to buy an electric truck? Do I not? How long can I run an R&G truck? All of that. Still, there’s no clear answers. I used to be in operations. You don’t want to go out and spend $10 million or $20 million refreshing your fleet, and all of a sudden it is obsolete, or the game changes, the rule changes. It’s convoluted and it’s making it tough on everybody. No one wants to be the person who makes a $2 million or a $50 million mistake.” The result, Lawson has observed, is the fear translates into inaction. “They say, ‘I’m not going to do anything.’ And that’s bad for the environment, it’s bad for them, it’s bad for everybody.” Nevertheless, he said, the presentations provided an important service to the industry. “Overall, I think it was extremely professional,” he said. “It was handled very well. I think everybody 9

who presented was professional, did a solid job, and was prepared. We (as presenters) had clear expectations. It was definitely one of the most professional forums I have been a part of.” The presenters for the June 20 “Plants” webinar were: Brandon Milar, CalAPA; Tim Olson, California Energy Commission; Camille Sultana, California Air Resources Board; Armando Infanzon,

Southern California Gas Co.; Katy Lamb, Pacific Gas & Electric; Greg Renegar, Astec; Jose L. LopezGallego, Versallis; and Scott Johns, Cleancor. Another scheduled speaker, Dennis Hunt with Gencor, was a last-minute scratch from the lineup due to a COVID-19 exposure. The presenters for the June 27 “Fleets” webinar were: Johanna Levine, assisted by Craig Duehring

and Krista Fregoso, California Air Resources Board; Ed Galindo, Volvo Construction Equipment & Services; Zach Lawson, Opal Fuels; and Drew Delaney with Associates Environmental. Recordings of each of the webinars have been posted to the on-line CalAPA “Knowledge Center.” Contact CalAPA to obtain a link to the recordings. Copies of the PowerPoint presentations delivered during the webinars are also available from the association. Cohen with Sespe Consulting, the CalAPA Environmental Committee co-chair, after hearing dire warnings about the future of energy reliability from the California Energy Commission, pressed the CARB presenters on the apparent disconnect between energy reliability and air quality regulations. Those concerns were echoed later by other industry representatives. As one presenter, Drew Delaney with Associates Environmental, stressed in his presentation, industry engagement on these and other issues are the only way to help highlight how policy disconnects may have dire consequences for the asphalt industry in California. “For regulatory compliance, fleet managers really need to be involved in rule-making activities that will potentially impact your fleet,” Delaney said. “The words that they (fleet managers) say are worth a lot more than the words I say. Hearing it from their mouth has a huge impact.” CA Russell W. Snyder, CAE, is executive director of the California Asphalt Pavement Association.


California Asphalt Magazine • 2022 Environmental Issue


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IN THEIR OWN WORDS: Excerpts from the ‘Future of Powering Plants & Fleets’ webinar presentations Editor’s Note: What follows are some noteworthy excerpts and “take-aways” from the CalAPAproduced June 20 “The Future of Powering Asphalt Plants in California” webinar and the June 27 “The Future of Powering Asphalt Fleets in California” webinar. Some comments have been edited slightly for brevity and clarity. Scott Taylor, Taylor Environmental Services (CalAPA Environmental Committee Co-Chair): “The idea was hatched that we should do a current state of knowledge with regard to both what regulatory agencies are doing, what manufacturers are doing, and what suppliers are doing to try to prepare for all of these changes. Many of these things are still in process, so this is the beginning of an evolving conversation that we will be having.”

Figure ES-1: California Total Energy Consumption Net Interstate Flow of Electricity 9%

Net Electricity Imports 0%

Coal 1% Natural Gas 28%

Other Renewables 8%

Biomass 4%

Hydroelectric 4% Nuclear 2% Motor Gasoline excl. Ethanol 22%

Other Petroleum 4% Residual Fuel 2%

HGL 1%

Jet Fuel 8%

Distillate Fuel Oil 7%


Natural Gas

Motor Gasoline excl. Ethanol

Distillate Fuel Oil

Jet Fuel


Residual Fuel

Other Petroleum




Other Renewables

Net Electricity Imports

Net Interstate Flow of Electricity

Source: CEC staff with data from the United States Energy Information Administration

Scott Cohen, Sespe Consulting, a Trinity Company (CalAPA Environmental Committee Co-Chair): “As it relates to the revision of the AB32 scoping plan, we are looking forward to gaining some insights on how agencies work together.” THE FUTURE OF POWERING ASPHALT PLANTS WEBINAR: Tim Olson, California Energy Commission: “You’re an electricity user and probably a natural gas user. And those are our targets. The big overall objective in state government policy is to reduce greenhouse gases. There are over 12

80 government interventions to do that.” “There are lots of challenges on the horizon as it relates to renewables. “Utilities for the most part have not owned any new (power) generation since the early 1980s. Private entrepreneurs do that.”

“Some industries … have been doing their own independent, onsite power projects. You are seeing a trend of larger electricity users building their own on-site power systems.” “We’re on a growth curve no matter what scenario you look at (with regard to electricity

California Asphalt Magazine • 2022 Environmental Issue

consumption). We have a shortfall right now. That can be significant in the summer. That’s why you’re going to see potential rolling blackouts, or scheduled interruptions, or whatever you want to call it. One of the trends for the next three to five years is we are going to have shortfalls. Shortfalls in power plant capacity, and shortfalls in energy availability. “Even though (state water regulators) know they (natural gas-powered plants) are big water users, (closing them) would have unintended consequences of power interruptions, blackouts, etc.” “Interim renewables, in the growth and storage, are going to take time to mature and get stabilized.” “80% of our natural gas comes from out of state.” Camille Sultana, California Air Resources Board: “Industrial emissions make up about a quarter of total emissions (in California).” “Achieving California’s ambitious greenhouse gas reduction targets, which were set by legislation or executive orders, require contributions across all emission sources in California.” “We have a lot of different programs that are targeting different sectors and complement one another. Opportunities for emissions reductions in the industrial sector fall broadly in four categories: Improving energy efficiency, fuel switching to low-carbon fuels, electrification of on-site processes, and carbon capture and sequestration. Overall, CARB’s programs are about achieving GHG reduction and, more or less, let each individual facility to find a pathway that is going to work best for them. We haven’t, for the most part, chosen a pathway, but we incentivize GHG reduction by the pathways that are most feasible for facilities.” “There’s a lot of work going into the (AB32) Scoping Plan to articulate

a vision for California that keeps the lights on, that tries to get environmental justice, environmental equity, that also achieves our GHG carbon emission goals. These are real visions that include economic modeling and health modeling and energy modeling. It’s trying to put forward a realistic vision that can be achieved.” Armando Infanzon, Southern California Gas Co.: “The Infrastructure Investment and Jobs Act passed last November provided unprecedented and historical funding opportunities to the clean fuel space. On the hydrogen side, the Department of Energy is allocating $9.5 billion to develop the hydrogen economy.” Katy Lamb, Pacific Gas and Electric Co.: “We’re looking at, what can we do to help commercial and industrial companies and plants to convert from higher GHGemission fuel to natural gas, and particularly to renewable natural gas? We are bringing on more and more renewable natural gas every day. This gas is coming from food processing plants, dairies, wastewater treatment facilities, biomass and other organic sources. Cleaner fuel is a key strategy to decarbonization.” “What we would like to do, as your partners, is be your navigation

California Asphalt Magazine • Environmental Issue

tool. We know that you are looking at this milestone ahead, and how you get there (“The Road Forward” asphalt industry net-zero carbon initiative) and we want to help and assist, and provide you with the information you need, to get there.” Greg Renegar, Astec: “Many things can be done to lower the energy costs in the overall operations of an asphalt plant.” “If you come to a modern asphalt plant you really can’t tell if it is making mix or not, unless you ask somebody.” “In an asphalt plant, anything that gets hot, that’s not a rock, is a waste of heat. If it gets hot, insulate it.” “When you start thinking about designing a burner, hydrogen has about a third of the BTU content as natural gas, 10 times the flame speed, almost two times the flame temperature, so you can imagine as you go up and up in the amount of hydrogen it changes everything that happens inside these burners we design to be very low NOx burners.” “If you reduce the moisture content of your stockpile by 1% … you knock 11% off your fuel required. When you combine Warm Mix Technology with that, you’re making some huge steps in using less fuel to make more mix.” 13

Jose L. Lopez-Gallego, Versallis: “Many things can be done electrically these days, but whether it makes economical sense comes down to cost. It depends on your cost for kilowatt hour.” “If there is any chance of on-site production, either of energy or hydrogen, that normally drives the operating costs down.” Scott Johns, Cleancor: “When we deliver the (LNG) fuel, it is important to understand that you have options, that there is what we call the virtual pipeline, bringing in liquid natural gas.” “Just because you are connected to a pipeline, that doesn’t mean that pipeline is always going to be running.” THE FUTURE OF POWERING ASPHALT FLEETS WEBINAR: Johanna Levine, California Air Resources Board (Off-Road Regulations): “We are in the process of adopting amendments to the off-road regulations. The (California Air Resources Board) will be considering those amendments at the end of this calendar year. What we’re going to be proposing is a tier phase-out … by fleet size (If the rules are adopted). What this means is that, for example, large fleets in 2024 will no longer be able to operate a Tier 0 piece of equipment. There will be some exemptions to this.” “Starting Jan. 1, 2024, fleets will be required to use renewable diesel, with some flexibility.” “The Carl Moyer (incentive) Program has provided over $1 billion in funding since 1998 for off-road projects. They have primarily funded repowers, which is replacement of an engine in a piece of equipment, or a replacement. There are eligibility requirements with the Carl Moyer Program. This program is run through your local air district.” 14

(With regard to future regulations and changes) “Lots coming up.” Craig Duehring, California Air Resources Board (On-Road Regulations): “I did see your polling. I did sense that (webinar attendees) are somewhat anxious about the complexity of our regulations. Our job is to try to reduce that anxiety and reduce that level of complexity so you guys at least get a purview of what we are doing and how to move forward.” “This is very similar to your smog-check program, but much simpler. But these tests are going to be required, and just like the smog-check, in order to continue to register your vehicle in the state

of California you’re going to have to comply with the tests and make sure the trucks are meeting the requirements.” “Our climate challenge is real, and it’s urgent. Our governor issued an executive order a year ago saying we’ve got to transition our California fleet to zero (emissions), not only the light-duty cars, but also the heavy-duty trucks. This is an up-and-coming regulation (“Advanced Clean Fleets Regulation”) on how we propose to meet that goal.” “There are 140 ZEVs (zeroemission vehicles in seven truck categories available for sale now in the United States). Zero-emission trucks are coming. They’re here. They are ready to go.”

California Asphalt Magazine • 2022 Environmental Issue

“We are not alone in California. We are setting some of the standards, but a lot of the states in the Union, as well as Canada … are following suit, following our lead if you will in adopting regulations. We fully anticipate the whole U.S. will adopt this at some point.” Drew Delaney, Associates Environmental: “The anxiety that fleet managers have from the complexity of fleet regulations may not necessarily come from any particular regulation, it is the fact that there are all these regulations laid on top of each other. I think that is a huge source of the complexity anxiety, and perhaps the cost as well because a lot of these regulations have different implementations that cost a fleet, from one year to the next, a considerable amount of money, and then maybe a lot less the next year, and maybe a lot

more the year after that, so it’s not really a flat expense curve for every single one of these regulations that are piled on top of each other.” “For regulatory compliance, fleet managers really need to be involved in rule-making activities that will potentially impact your fleet. The words that they (fleet managers) say are worth a lot more than the words I say. Hearing it from their mouth has a huge impact.” “Fleet managers should avoid falling behind in the state of the industry knowledge of the equipment.” “Don’t get complacent on new or amended regulations. Always stay on top of them. Something could come along that impacts you sideways.” “Pet equipment that sits in a yard because someone has an emotional attachment to it is not a good idea.”

“Please (don’t) purchase equipment without proper knowledge of their regulatory obligations. Make sure, when you sell vehicles, that you provide the new owner with the proper disclosure of the regulatory applicability.” Ed Galindo, Volvo: “When you take out that diesel engine, you don’t have to worry about the diesel engine filter, the engine oil filter, etc., and also don’t have to worry about the fuel costs.” Zach Lawson, Opal Fuels: “We are definitely fuel agnostic. We are involved in multiple hydrogen projects, as well as doing a lot of electric projects as well. It’s all about the numbers, and what it means, exactly to your application.” CA

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QUESTIONS & ANSWERS ‘The Future of Powering Asphalt Plants in California’ webinar Presented by the California Asphalt Pavement Association

Editor's Note: The following questions were posed in writing during the June 20, 2022 CalAPA webinar titled, “The Future of Powering Asphalt Plants in California.” Since time ran short, we have relayed the questions to the appropriate presenter and the questions and answers we have received are presented below. In some cases, a question was answered by more than one person. We have provided a list of the various presenters should you wish to contact them directly to obtain additional information. Question: Is cement going to be added to the Buy Clean CA Act? Answer: Adding any new materials to the Buy Clean CA Act is dependent upon action from the legislature. SB 778, which would add concrete (not only cement) materials to the Buy Clean CA Act, was proposed in the California legislature during the 2022 legislative cycle. (Answer supplied by Camille Sultana of the California Air Resources Board). Question: Are there plans to incentivize GHG reductions through CARB or the Legislature? Answer: 1. CARB’s existing Capand-Trade Program is California’s primary regulation promoting industrial facility decarbonization. The Capand-Trade Program imparts an economy-wide price on carbon and covers approximately 80% of GHG emissions in California. 16

2. SB 596, which was passed by the California legislature and signed by the Governor in 2021, requires CARB by 2023 to develop a strategy to achieve net-zero emissions associated with cement used in California by 2045. 3. In the current session, legislation has been proposed for additional strategies to decarbonize building materials. Currently proposed legislation includes SB 778, which would add concrete to the Buy clean California Act, and SB 1297 which would direct the Natural Resources Agency to develop a plan to advance low-carbon materials and methods in building and construction projects. (Answer supplied by Camille Sultana of the California Air Resources Board). Question: Do you foresee a realistic alternate fuel for asphalt burners that could replace natural gas as the primary fuel? Answer: Renewable natural gas could be utilized as a replacement drop-in fuel for natural gas. Additionally, various fuel-consuming processes at asphalt plants could potentially be electrified. The best pathway to decarbonization is dependent upon facility-specific characteristics. (Answer supplied by Camille Sultana of the California Air Resources Board).

Question: Does Astec or Gencor currently offer an electric burner (drum)? Answer: No, we do not offer an electric aggregate dryer at this time. Most electric heat is used in heating the AC (AC tanks) or hot oil (electric hot oil heater). (Answer supplied by Greg Renegar of Astec Industries) Question: How would they get hydrogen incorporated to use as a fuel at an asphalt plant? Answer No. 1: Direct injection/ blending from the utility provider into the NG pipeline. They can usually do this up to about 20+% until they get into issues with material properties of the gas train components. (Answer supplied by Greg Renegar of Astec Industries). Question: How would they get hydrogen incorporated to use as a fuel at an asphalt plant? Answer No. 2: Their heaters could (most probably) use hydrogen instead of what they are using now, they would have to change the burners though. Burners for hydrogen are not an issue, however NOx and other temperature-related parameters will have to be monitored. Hydrogen can be sourced from traditional suppliers like Air Liquide, Praxair, etc. Also can be locally produced, can be worth it in certain conditions. (Answer supplied by Jose L. Lopez-Gallego, Versallis)

California Asphalt Magazine • 2022 Environmental Issue

Question: What are other countries doing? Are there any plants actually using hydrogen? Answer No. 1: No. Most of the large European equipment manufacturers are focusing on things like biofuels, e.g., wood dust, which are more readily available there than NG. For US domestic uses, this is often not practical due to the shipping cost and carbon footprint associated with the logistics of shipping these solids across country. There are also emissions concerns with burning wood products, even though the source of the fuel is technically “renewable” due to tree regrowth, although rather slow. Lastly, there are power issues with reducing the wood to a size that burns efficiently with current burner technology.

(Answer supplied by Greg Renegar of Astec Industries) Question: What are other countries doing? Are there any plants actually using hydrogen? Answer No. 2: There is much noise but not much being actually done. Companies in Spain, Switzerland, Germany, France, UK .. are testing different alternatives and evaluating costs. (Answer supplied by Jose L. Lopez-Gallego, Versallis) Question: Does CLEANCOR sell renewable natural gas? Answer: CLEANCOR does sell RNG for 100% of our on-road operations nationwide. Also, our hydrogen supply is green or

renewable hydrogen coming from our RNG supplies and solar farms processed through our SMR technology. (Answer supplied by Scott Johns, CLEANCOR LNG LLC). Question: Does CLEANCOR sell renewable propane? Answer: CLEANCOR does not supply propane – we transition customers from operating on propane to operating on natural gas via our LNG solutions. LNG provides for a more stable and cleaner source of fuel for the markets we service. (Answer supplied by Scott Johns, CLEANCOR LNG LLC). CA



Russell W. Snyder, CAE


Scott Taylor

Taylor Environmental Services

Scott Cohen

Sespe Consulting (Trinity)

Brandon Milar, P.E.


Tim Olson

CA Energy Commission

Mark Sippola

CA Air Resources Board

Camille Sultana

CA Air Resources Board

Armando Infanzon

Southern California Gas Co.

Katy Lamb


Greg Renegar


Dennis Hunt


Jose Lopez-Gallego


Scott Johns


California Asphalt Magazine • Environmental Issue


FACT SHEET: Environmental Product Declarations (EPDs) The asphalt industry collaborates with owners, others on sustainable solutions By the California Asphalt Pavement Association


s part of a broader sustainability initiative, California Asphalt Pavement Association (CalAPA) has worked collaboratively with public and private owners, community representatives, regulatory agencies, researchers and other interested parties over the years on sustainability issues, and the development of Environmental Product Declarations (EPDs) have been a prominent part of that ongoing initiative. In addition to working with public works agencies, such as the California Department of Transportation (Caltrans), to develop and implement EPD pilot projects, CalAPA continues to educate the asphalt pavement industry and our public agency partners on the state of the practice in close coordination with the National Asphalt Pavement Association, which has developed the “Emerald EcoLabel” EPD tool. What follows are some resources for those seeking additional information on the “Buy Clean California” law as it relates to the asphalt pavement industry, as well as specific information on EPDs, which are an integral part of the Buy Clean California Act implementation. Buy Clean California The “Buy Clean California Act,” originally signed into law Oct. 15, 2017, mandates the collection of Environmental Product Declarations (EPDs) for eligible materials (initially carbon steel rebar, structural steel, flat glass, and mineral board insulation). The link to the law is codes_displayText.xhtml?lawCode=PCC&division=2.& title=&part=1.&chapter=3.&article=5. The California Department of Transportation (Caltrans), the largest consumer of asphalt in California, has been working on an initiative since 2018 to seek the production of EPDs on many other materials used by the department in construction of transportation improvement projects, including asphalt. The Caltrans Buy Clean California/EPD website is https://www.dgs. The website includes a status report on the pilot projects Caltrans has initiated to include EPD language on projects put out to bid by the department, including asphalt pavement projects. 18

Environmental Product Declarations (EPDs) The Buy Clean California Act of 2017 contains language that a successful bidder for a project of a specified material “submit a current facility-specific Environmental Product Declaration, Type III, as defined by the International Organization for Standardization (ISO) standard 14025, or similarly robust life cycle assessment methods that have uniform standards in data collection consistent with ISO standard 14025, industry acceptance, and integrity, for each eligible material proposed to be used.” In general terms, an EPD is a report that seeks to quantify the environmental impact of an asphalt mix. The asphalt industryrecognized standard for EPDs has been developed by the National Asphalt Pavement Association (NAPA) and is known as the “Emerald Eco-Label.” The Emerald Eco Label has been accepted for use in California by Caltrans and other agencies. The NAPA website devoted to this topic is engineering-services/environmental-productdeclarations. The tool, and the “Product Category Rules” that form the basis of the EPD, continue to be evaluated and refined as new information about the environmental lifecycle assessment (LCA) of manufactured asphalt and its various constituent parts continue to be studied and reported. CalAPA EPD-related educational resources CalAPA has been working to educate the asphalt pavement industry in California about environmental lifecycle cost (LCA) and Environmental Product Declarations (EPDs) for many years. A few of the association’s more popular resources are listed below: At the CalAPA Spring Asphalt Pavement Conference held in Ontario on March 20, 2019, the Caltrans EPD project manager, Jackie Wong (who was also featured in a CalAPA educational webinar in [ Continued on page 20 ]

California Asphalt Magazine • 2022 Environmental Issue

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January of 2019), gave an update on the EPD program and goals. The link to her presentation is https://www. At the same conference a presentation was made on a contractor’s perspective on EPDs, presented by Greg Reader of George Reed, Inc. The link to that presentation is CalAPA has written several authoritative articles about EPDs in is various publications and member communications, including the association’s magazine, “California Asphalt.” The 2017 environmental issue article on EPDs is docs/cam_environmental_issue_2017_online?e=61858 70/49787070. An update was published in the 2020 issue of the magazine docs/cam_enviro_-_book_-_low_res?fr=sOTgxMjE2ND A2MTc. Another EPD update article that appeared in the magazine in 2021 is docs/cam_enviro_2021_-_issuu?fr=sODVlYTQwMT YwMjg. Additional information on EPDs and other environmental-related topics as they relate to asphalt

is available from CalAPA, including fact sheets, publications and other information. Some of those resources are posted on the CalAPA “Asphalt in Your Community” webpage community.html. EPDs are part of a broad, national emphasis on sustainability CalAPA works closely with its national partner, the National Asphalt Pavement Association (NAPA), in the development of sustainable business practices for the asphalt pavement industry. The NAPA website that summarizes many of the industry’s sustainable initiatives is A major initiative launched in 2022, “The Road Forward,” which articulates a vision for a Net-Zero Carbon Emissions future for the asphalt pavement industry in response to climate change, includes many elements mentioned here, including EPDs. Additional information on The Road Forward initiative can be found https:// For further information on these or other sustainable asphalt pavement industry initiatives as they relate to California, contact CalAPA at (916) 791-5044 or visit the association’s website at: CA

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California Asphalt Magazine • 2022 Environmental Issue

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FACT SHEET: Information about asphalt plants, neighborhoods and the environment By the California Asphalt Pavement Association


sphalt plants mix liquid asphalt binder (asphalt cement) with crushed rock, gravel, and sand to create the asphalt pavements you drive on or walk on every day. Asphalt cement is also called bitumen. Asphalt production is necessary to maintain the road systems throughout the United States and here in California. In fact, over 90 percent of all paved surfaces in the United States are surfaced with asphalt, and that figure is 95 percent in California. Locating asphalt production facilities in logistically strategic areas reduces distance that materials must travel from source to jobsite, lowering greenhouse gas emissions (GHG) associated with product transport and allowing rapid response to the needs of communities that are distant from urban or industrial areas. Proper and timely maintenance of roadways decreases infrastructure costs for these communities as well as promoting more efficient travel for all users of asphaltpaved roads. Finally, studies show well-maintained roads reduce costs to motorists by hundreds of dollars per year due to lost fuel economy and vehicle repairs. Hot Mix Asphalt (HMA) and Warm Mix Asphalt (WMA) production The Federal Highway Administration (1) describes Hot Mix Asphalt (HMA) as the traditional process for constructing asphalt pavements. It is manufactured in a central mixing facility by heating crushed rock and sand (aggregates) and asphalt binders above 300°F. It is kept hot during transport by truck, placement (where it is spread on the roadway by an asphalt paving machine), and compaction (where it is compacted by a series of asphalt roller machines to a finished surface that is strong, flexible and durable). The mixture cools after compaction to form the asphalt pavement. Warm Mix Asphalt (WMA) production uses the same process but temperatures generally start 10° to 50°F lower during mixing and remain lower during trucking, placement, and compaction. The lower temperature used in WMA manufacturing reduces emissions and odors. Depending on the production temperature, a range of 15-70 percent reduction of carbon dioxide and other emissions during production have been reported. Also, because production temperatures are lower, less fuel is needed to heat the asphalt. The reported reduction in fuel consumption typically 22

ranges from 20-35 percent, with up to 50 percent reported for some technologies. Asphalt product emissions In California, the operation of asphalt plants are highly regulated by the California Air Resources Board (CARB), regional air districts, the State Water Quality Control Board (SWQCB), the California Department of Industrial Relations, Division of Occupational Safety and Health (Cal/OSHA), the California Department of Resources Recycling and Recovery (CalRecycle) and many other local, state and federal agencies. The U.S. Environmental Protection Agency (U.S. EPA) also regulates emissions from asphalt facilities and requires close monitoring of emissions to ensure that they meet air regulation requirements. In 2002, the U.S. EPA reviewed emissions from asphalt plants and determined that they were not a major source of air pollution. In 2004, the U.S. EPA measured HMA plant emissions by extensive air emission studies conducted at four sites and found them to be low (3) . Asphalt plants employ multiple emission control systems as directed by regulations and may include monitoring to ensure that emissions of particulate matter, carbon monoxide, sulfur dioxide, nitrogen dioxide, and lead comply with the National Ambient Air Quality Standards (NAAQS) at the property boundary (4) . The small amount of emissions released from these control systems are closely monitored to ensure they stay well below any permitted level set by regulators to ensure that they pose no health or environmental risk to nearby communities (5) . Most visible emissions from an asphalt plant’s stack are just steam resulting from the drying of aggregate (2, 5) . Low air emissions from HMA production have been confirmed by air monitoring data collected by state and federal agencies in communities near HMA plants. These data show air concentrations of HMA chemicals are typically below air criteria established by state authorities and for some chemicals, below background concentrations (6, 7) . Health Hazard Asphalt emissions have raised concerns in communities and these concerns have been investigated by state and federal agencies. When detailed health California Asphalt Magazine • 2022 Environmental Issue

Above: Patwin Elementary School playground in Davis, CA. Right: A photo of schoolyard and bikes in Davis, CA.

effects studies were undertaken around asphalt plants (specifically Hot Mix Asphalt facilities), no health effects from the plants were identified. In a six-year study performed in North Carolina in response to community concerns, both state and federal agencies concluded that there were no increased health hazards or risks associated with emissions from asphalt facilities as compared to areas without asphalt facilities (8, 9, 10) . Other studies and state regulatory bodies have also found that asphalt plants, in general, do not pose an elevated health risk to surrounding communities (5, 11, 12) . Since air emissions from HMA facilities are low, it is not surprising that health effects have not been identified in communities around asphalt production facilities. In fact, the International Agency for Research on Carcinogens (IARC) lists asphalt (bitumen) paving exposures to workers as being in the same category of hazard as cell phone radio frequency electromagnetic fields or coffee (Class 2B) (13, 14) . Further, as described by the Colorado Department of Public Health & Environment (DPHE) (2), a typical asphalt facility does not generate hazardous waste and generates very little solid and universal waste. Some wastes (such as petroleum-contaminated soils or recycled asphalt) and waste from other industries (such as used tires) may be reused in the asphalt production process. In all cases, all wastes must be properly managed and disposed (2) . In California, that process is overseen by the California Department of Resources Recycling and Recovery (CalRecycle) and there are strict reporting requirements. In California, an independent panel of scientists, the Carcinogen Identification Committee, part of the State of California, Office of Environmental Health Hazard Assessment, reviewed all relevant studies on asphalt and ultimately concluded in 2016 that asphalt was a “low priority” for further study, and therefore not eligible for inclusion in the state’s official list of Proposition 65 substances known to cause cancer or birth defects (19) . In the Information Age, so much information on health exposures is available, but not all of it in context and evaluated by experts in the field. According to a California Asphalt Magazine • Environmental Issue

publication of the California Environmental Protection Agency (CalEPA), “Health risk assessment requires both sound science and professional judgement and is a constantly developing process.” (21) . Exposures Asphalt pavement is 95 percent small stones, sand, and gravel, and about 5 percent asphalt binder cement (“bitumen”). In addition, asphalt pavement may use recycled materials such as glass, recycled pavement, used tires or recycled plastic. As determined by the U.S. EPA (2002), emissions from asphalt plants have not been a major source of air pollution, and asphalt plants are regulated by state and federal authorities. In addition, emissions have been furthered reduced in recent years due to process improvements. Exposures to emissions at production facilities and paving sites have decreased up to 98 percent since 1970 (5) due to process improvements, lower temperature production, and use of natural gas in place of traditional petroleum products. In fact, the National Institute of Occupational Safety and Health (NIOSH) has recognized process change (warm mix asphalt) as a prime example of reducing or eliminating emissions (18) . In 2018, an update to a review of emissions from asphalt plants was published, providing comparisons of emissions from asphalt plants to other source of air pollutant emissions and typical background values (16) . The estimated emissions from an asphalt facility that produces 200,000 tons of asphalt per year were also compared to those generated by woodstoves and fireplaces, fast food restaurants, breweries, and gas filling stations. The results of the background comparison, below (TABLE 1), show that emissions from asphalt plants are below typical background concentrations (16) : 23

a) Estimate at 1000 feet from facility, includes stack and fugitive emissions b) Range of values indicating typical or low end to high end in background samples or modeled values at 250 feet and 3000 feet from APM facility c Per Sanborn-Head 2018, the upper value is PM2.5 levels in indoor air of homes heated by residential wood stoves Further, the study found that the typical emissions from an APM plant producing 200,000 tons of asphalt per year were equivalent to the following annual emissions: • Total Volatile Organic Chemicals: 4 mid-size breweries, 20 residential fireplaces, or 5 gas refilling stations • Benzene: 19 residential wood stoves or 1 gas refilling station • PAHs: 21 Fast food restaurants or 180 residential wood stoves • Formaldehyde: 7 Fast food restaurants or 150 residential fireplaces. The estimates provided in the Sanborn report (2018) were based on the emissions from an HMA facility; the emissions from a WMA facility would be lower than an HMA facility, as production and holding temperatures are lower and emissions are therefore reduced. In 2021, the City of Irvine, Calif., commissioned a study of the air quality near an asphalt plant “in response to concerns raised by nearby residents.” The “multi-pronged emissions investigation” found “no elevated levels of air toxics detected” and “air toxic monitoring levels below long-term health-based threshholds.” The study included air samples collected by the South Coast Air Quality Management District, which found the results “within background levels,” and by the City of Irvine, which took samples from multiple locations for over 100 individual compounds and found that the “results show most concentrations are within typical regional background levels.” (22) . 24

Process Changes As the asphalt industry strives to maintain a safe and healthy workplace for their employees and communities, process improvements have been implemented to decrease emissions and improve safety. The asphalt pavement industry has implemented technological advances to reduce an asphalt plant’s environmental footprint. These advances have helped reduce the amount of energy needed to make asphalt pavements and have expanded the use of recycled materials in asphalt pavements, as well as lowering emissions (5) . Lower Production Temperatures Warm Mix Asphalt (WMA) is the general term for a variety of technologies that allow production of pavement material at lower temperatures. It has been proven to reduce fuel emission, fumes, and odors (17) . WMA production methods use temperatures 30 to 120 degrees Fahrenheit lower than traditional hotmix asphalt. Because less energy is needed to heat the asphalt mix, less fuel is needed to produce WMA. Fuel consumption during WMA manufacturing is typically reduced by 20 percent (17) . Emission from APM facilities are therefore reduced through use of less fuel and because lower temperatures means lower emissions from the asphalt itself. Use of Natural Gas as APM Plant Fuel Source Most emissions at asphalt mixing facilities come from the combustion of fuel, such as natural gas, that are used to dry and heat the rock or aggregate and keep the asphalt at the temperature needed for use and placement at paving sites (5) . As reported by the Colorado Department of Public Health and Environment, best management practices to minimize emissions during asphalt pavement material production have been established by the asphalt industry and include guidance on facility operation and maintenance to maximize efficiency and minimize emissions. Natural gas is a common fuel for asphalt plants, which is cleaner-burning than other types of fuel (2) . [ Continued on page 26 ]

California Asphalt Magazine • 2022 Environmental Issue

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Baghouse/Air Filter Improvements Baghouses consist of several rows or compartments of fabric filters that collect the dust during the operation of an asphalt plant. They capture dust that may be released from the drying of aggregates (5) . Modern baghouse designs use more efficient media, improved cleaning, and structural enhancements to provide a more predictable, cost-effective, and energy-efficient filtration solution. Other technology used by asphalt plants to control emissions include counter-flow mixing equipment technology, enclosed or partially enclosed conveyor systems, and top-of-silo emission recovery systems (2) . Since 1970, stack emission has decreased 97 percent while asphalt production has increased 250 percent (5) because of improvements in emission controls. Recycling Asphalt is 100 percent recyclable, and is perhaps the most reused and recycled product in the United States and in California. In fact, the National Asphalt Pavement Association reports that asphalt binder recycled from old pavements and roofing shingles replaces more than 21 million barrels of oil per year, saving American taxpayers more than $2.2 billion annually. This also reduces emissions, both from asphalt production and the shipment of oil (5) . Hot and warm mix asphalt paving materials are a mixture of gravel and small stones (aggregate), sand, and asphalt binder, and may include recycled asphalt pavement (2, 5) . In addition to recycled asphalt pavement, other materials may be recycled into asphalt pavements including rubber from used tires, glass, recycled plastic and asphalt roofing shingles (5) . Asphalt pavement can be recycled repeatedly in new asphalt pavement mixes, and using reclaimed materials means less new material must be produced (5) . Standard specifications published by the California Department of Transportation (Caltrans) and many local agencies permit the use or RAP in pavement mixes. Diverting used tires from California landfills is a goal of CalRecycle, and the use of rubber from scrap tires in asphalt is in widespread use in California. About 46 percent of asphalt used by Caltrans on freeways and highways includes Crumb Rubber Modifier (CRM), diverting the equivalent of 5.5 million tires a year (20) . Greenhouse Gas (GHG) emissions In the most comprehensive industry inventory done to date, the National Asphalt Pavement Association (NAPA) in 2022 published a report titled, “GHG Emissions Inventory for Asphalt Mix Production in the United States (SIP 106),” as part of the broader “The Road Forward” net-zero carbon initiative. 26

Above: Asphalt was used during construction of the eastern span of the San Francisco-Oakland Bay Bridge. The Bay Bridge, which carries more vehicular traffic than any other bridge in California, connects San Francisco and Oakland and spans San Francisco Bay, one of the most ecologically sensitive areas of California.

The report found that “cradle-to-gate” emissions associated with asphalt mix production in the United States represented approximately 0.03% of total U.S. greenhouse gas emissions in 2019. By comparison, U.S. EPA data indicate that transportation emissions from fossil fuel combustion represented 27.8% of total emissions in 2019, while industrial emissions represented 25.3% (23) . Summary/Conclusion Asphalt plant facilities play a vital role in the maintenance of our nation’s infrastructure and strive to be good neighbors in the communities they serve. The emissions from these facilities are even lower today as process improvements are now best management practices to reduce emissions and odors and increase the use of reclaimed materials. Compared to other pavement materials, asphalt pavement has a very small carbon footprint and has been recognized by the U.S. Department of Energy as a top material for sequestering carbon (5) . CA California Asphalt Magazine • 2022 Environmental Issue

References: 1. Federal Highway Administration, Department of Transportation. Warm Mix Asphalt FAQs https://www. cfm#hot) 2. Colorado Department of Public Health and Environment (CDPHE). Fact Sheet – Environmental Regulations for Hot Mix Asphalt Plants. Air Pollution Control Division, Small Business Assistance Program. August 2014. 3. EPA 2004. AP-42. Compilation of Air Pollutant Emission Factors, Fifth Edition, Vol. 1, Chapter 11: Mineral Products Industry. 4. National Ambient Air Quality Standards. ( 5. National Asphalt Pavement Association. 2014. The Environmental Impact of Asphalt Plants SR 206 2014-05. 6. North Carolina Division of Air Quality (NCDAQ). 2003. Salisbury Air Quality Monitoring Study. 7. Agency for Toxic Substances and Disease Registry (ATSDR). 2005. Health Consultation: Evaluation of Exposure from the Former Valley Asphalt Production Site, Spanish Fork, Utah County, Utah. 8. Agency for Toxic Substances and Disease Registry (ATSDR). 2006. Review of the Incidence of Cancer Cases among Residents of Rowan County, North Carolina, and Residents Living Near Industrial Facilities in Salisbury, North Carolina. 9. Agency for Toxic Substances and Disease Registry (ATSDR). 2007. Health Consultation: APAC Carolina Inc and Associated Asphalt Inc. Jake Alexander Boulevard. Salisbury, Rowan County, North Carolina 28144. 10. Campbell, D. 2006. Cancer and Suicide Near Asphalt Distribution Facilities: Salisbury, North Carolina. A Report of a Six-Year Investigation. 11. New Hampshire Department of Environmental Services. 2011. Environmental Factsheet ARD45. Road Paving Asphalt. 12. Oregon Department of Environmental Quality. 2013. Fact Sheet: Hot Mix Asphalt Emissions. 13. International Agency for Research on Cancer (IARC). 2011. Occupational Exposures to Bitumens and their Emissions. World Health Organization. October 18, 2011. 14. IARC. 2013. Non-Ionizing Radiation. Part 2: Radiofrequency Electromagnetic Fields, Volume 102. IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. 15. Federal Register (FR). 2002a. Vol.167, No. 29, p.6552, National Emission Standards for Hazardous Pollutants: Revision of the Source Category List Under Section 112 of the Clean Air Act. Tuesday, February 12. 16. Sanborn- Head. 2018. Emissions Comparison: Asphalt Pavement Mixture Plants and Select Source Categories. Prepared for the National Asphalt Pavement Association, File No. 4197.02. December. 17. Federal Highway Administration 2016. Warm Mix Asphalt Factsheet. Available at innovation/everydaycounts/edc-1/wma.cfm 18. National Asphalt Pavement Association (NAPA) 2011. Presentation for Asphalt Paving Workers titled “IARC Monograph: Occupational Exposures to Bitumens and their Emissions December 1, 2011.

California Asphalt Magazine • Environmental Issue

19. Prioritization 2016: Chemicals for Consultation by the Carcinogen Identification Committee: 20. Caltrans report, “2018 Crumb Rubber Report: Cost Differential Analysis Between Containing Crumb Rubber and Conventional Asphalt” (2020) media/dot-media/programs/maintenance/documents/ office-of-pavement-programming/2018-crumb-rubberreport-approved-version-for-web-posting-without-issuememokaa11y.pdf 21. A guide to Health Risk Assessment, California Environmental Protection Agency, Office of Environmental Health Hazard Assessment (2001) 22. South Coast Air Quality Management District & City of Irvine “Community Air Monitoring” Fact Sheet dated Aug. 24, 2021. 23. “GHG Emissions Inventory for Asphalt Mix Production in the United States” SIP-106 (2022) Shacat, J., Willis, J. & Ciavola, B. Published June 2022 by the National Asphalt Pavement Association.

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CalAPA engages the South Coast Air Quality Management District on proposed rules covering ‘fugitive dust’ from large roadway construction projects By Russell W. Snyder


ore than a year of engagement by CalAPA and other stakeholders have resulted in important changes to proposed rule language covering fugitive dust generated by large roadway construction projects in Southern California. The proposed rule, 403.2, being developed by the South Coast Air Quality Management District, took aim at large demolition piles and associated crushing and grinding equipment typically employed during pavement and bridge reconstruction. Previously, the proposed rule was labeled 1157.1. The agency oversees air quality regulation and enforcement for large areas of Los Angeles, Orange, Riverside and San Bernardino counties, including the Coachella Valley. The region is home to about 17 million residents, or about half the population of the entire state of California. The SCAQMD first signaled its intention in early 2021 to take a close look at the air quality impacts of this type of activity to residents living near such projects, and convened the first working group meeting on the topic on July 15, 2021. It was clear from the outset that air district regulators were a bit unclear exactly how to define a “large roadway project,” and what type of equipment and activity typically takes place on such work zones. A growing chorus of stakeholders raised objection to early versions of the rules, and CalAPA enlisted 28

A project stockpile is a smaller version of a plant stockpile (pictured). Photo supplied by Graniterock.

the expertise of the California Department of Transportation (Caltrans) construction and environmental experts in Southern California and at the Caltrans headquarters offices in Sacramento. CalAPA’s chief objections were that the proposed rule was redundant, ill-defined and would hamper desperately needed road improvement projects in the region. In a formal letter sent by CalAPA to the air district in January, CalAPA outlined these and other objections, and followed up with recommended language changes with regard to the size of debris piles, height of crushing equipment and other provisions. CalAPA and its members have a long history of working with regulators to help them understand the asphalt pavement industry, hosting plant tours and visits to

construction sites around California. In 2020, during engagement with the SCAQMD on another rule, regulating aggregate burners on asphalt plants, CalAPA member Sully-Miller hosted a "virtual" plant tour and demonstration of its various control measures installed at an asphalt plant. In the Sacramento and the San Francisco Bay Area, CalAPA has coordinated tours of asphalt plants for air quality and water quality regulators to further raise awareness of plant operations and the many strict environmental, health and safety regulations that govern them. In a March 11 letter to the air district, the association called out industry concerns that had not been addressed in an early revision of the rule language, and said the rule as it existed then “could create hazards for the safe navigation

California Asphalt Magazine • 2022 Environmental Issue

of the work site by construction crews and equipment, as well as the motoring public.” Further, the CalAPA letter said, the proposed rule may actually generate more emissions by requiring more truck trips to move pavement grinding stockpiles that are temporarily stored at active road construction sites. Caltrans, meanwhile, shared with the air district other innovative pilot projects the department is implementing in Southern California to address concerns about air quality in neighborhoods adjacent to where temporary road work is taking place. A coalition representing utilities, and also other business interests, is closely monitoring the rule-making process. CalAPA's longstanding position, as outlined in previous letters to the SCAQMD, is to support air quality regulations that are "reasonable, achievable and quantifiable."

By April, the rule language had gone through a half-dozen revisions and a SCAQMD committee reviewing the rule language agreed to significant language changes with regard to the height of stockpiles, crushing equipment, on-site storage and monitoring. Industry representatives indicated the language changes eliminated or mitigated the most problematic parts of the original proposal. Significantly, during a meeting April 15, members of the SCAQMD's Stationary Source Committee and air district staff agreed in principle that rule language related to the height of piles of grounded up aggregate, asphalt and other material from pavement rehabilitation projects should match the typical size of piles created by portable grinding equipment and conveyors found on such jobs, which is about 30-feet. Having many more, smaller piles on a project could pose

the potential for more dust to be generated to nearby neighborhoods, regulators concluded. However, regulators did not seem inclined to delay the rulemaking process as was requested by numerous stakeholders, as well as Caltrans. The air district released the latest version of the proposed rule on May 3 and indicated it would continue to accept public comment. No date for final rule vote and adoption had been set as of the end of July. The CalAPA Environmental Committee continues to closely monitor the proposed rule and will report significant developments to the membership. CA Russell W. Snyder, CAE, is executive director of the California Asphalt Pavement Association.


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‘Hyperlocal’ air monitoring adds another layer of complexity, potential for confusion in the air quality debate By Scott Cohen


n past issues of California Asphalt magazine we examined changes to California health risk assessment methodologies and suggested it may be desirable to sample for metals concentrations in fugitive dust or other pollutants and/or emissions sources at an individual operation. Many of the changes discussed in those articles were driven by increasingly strident environmental justice campaigns and Assembly Bill AB617 (Garcia, 2017). The wording of AB617 is sufficiently vague so that regulatory language not envisioned or explicitly authorized by the legislation are nevertheless being pushed by advocates waving the AB617 banner. Politically, environmental justice gives agencies cover for claiming wide-reaching regulatory authority that otherwise could not be justified. This dangerous development may pose a threat to the asphalt pavement industry in California. For those who may have not been following AB617 closely, some background may be helpful. The bill was introduced in the California Legislature on Feb. 14, 2017 by Assemblywoman Christina Garcia, D-Bell Gardens (58th Assembly District) and picked up the bill designation number Assembly Bill 617, which in shorthand has come to be known as AB617. It requires the California Air Resources Board (CARB), working with local air districts, to develop a uniform statewide system of annual monitoring and reporting of emissions from stationary sources, with criminal and civil penalties for non-compliance. The bill also supports the formation of local


community air boards. The bill passed the Legislature and was signed into law by Gov. Jerry Brown (D) on July 26, 2017. Some key features of AB617 include: • Identification of adversely communities impacted by air pollution. • Developing a statewide air monitoring plan (rather than regional plans that were in pace previously). • Creating district and communityoperated networks. • Publishing data collected by facilities and citizens statewide on the internet. • Developing state and district emission reduction strategies. • Creation of a statewide BACT/ BARCT Clearinghouse (“Best Available Control Technology / Best Available Retrofit Control Technology”). • Development of system to input new determinations on BARCT. • A uniform system of statewide emissions reporting. • Development of a statewide pollution mapping tool. Air district regulators say they want to avoid duplicative reporting to CARB and local air districts, but industry raised concerns in this area, and local air districts privately

fretted about the aggressive implementation schedule and resources needed to implement the new law. Some community air district meetings have been contentious, and recently three members of the San Joaquin Valley Air Pollution Control District’s Public Advisory Group resigned in July, with one departing member telling a local newspaper the “process was a sham.” A key provision of AB617 provides grant funding to “grassroots” organizations that want to perform their own monitoring of air pollutants in their communities. Concurrently, low-cost monitors came to market that were capable of uploading raw data to a crowd sourced website. The monitors were already problematic in terms of accuracy when properly operated by qualified personnel. In the hands of untrained members of the public, however, the likelihood of obtaining meaningful data drops substantially. Both industry and air agency experts expressed concern over the data produced by these monitors, which appropriately undermined their legitimacy and use. As if this situation was not complex enough, a new dynamic has come upon the scene: “Hyperlocal,” mobile air monitoring. Aclima is a company that, on its website, states: “Measuring air, everywhere.” The website goes on to say, “Block by block, we’re putting air pollution and greenhouse gases on the map. Groundbreaking hyperlocal data and analytics to reduce emissions, improve public health, and deliver clean air for all.” A tall order, to be sure. But how do they deliver on that promise?

California Asphalt Magazine • 2022 Environmental Issue

Recently released Aclima Community Air Reports contain a significant amount of information and mark a milestone in how air quality is visualized. The interactive online report format does an excellent job making complex data simple and accessible to the public, including on a free mobile phone app. The company has secured government contracts to gather and report this information in California and New York. One example of such a report was prepared for the Muscoy Community in San Bernardino. Representative figures and quotes from that report are provided in this article and much of the methodology discussion below is paraphrased from the report, but other reports exist, such as a website devoted to San Francisco Bay Area data, and presumably many more are in the works. SAN BERNARDINO/MUSCOY COMMUNITY AIR REPORT The report discussed in detail below was presented by Aclima staff to the San Bernadino and Muscoy (SBM) Community Steering Committee (CSC) during the Feb. 10, 2022 meeting starting at 1:08 in the recording hosted by South Coast Air Quality Management District (SCAQMD) on Facebook. SCAQMD has also created a “Story Map Journal” similar to the Aclima web approach for the SBM Community. The Aclima report says it measured air pollution on “all publicly accessible streets, block by block, in the AB617 communities of San Bernardino and Muscoy.” This area is located in the SCAQMD jurisdiction, approximately 54 miles east of downtown Los Angeles. The neighborhoods in this community include San Bernardino and Muscoy. The SBM community is 31 square miles with a population of approximately 152,000. In the AB617 SBM community, Partial Zero Emissions Vehicles equipped with proprietary, multipollutant, mobile air quality

Figure 1. PM Indicator: Action

Note: Screenshot of PM 2.5 Indicator and “action” that Aclima suggests may be taken. Sensitive receptors are shown as icons that may be clicked to access more information.

measurement units were deployed to produce high-time resolution (1-second) air quality measurements. The collection methodology was designed to capture hyperlocal data representative of mean ambient concentrations for each road segment driven over a 3-month collection time period from July 1 through Sept. 30, 2021. Mean concentrations are based on individual 1-Hz measurements averaged over the length of a single drive over a ~100 meter road segment (single pass mean). The set of single pass means for a road segment is then aggregated over the collection time period, resulting in a median concentration for that segment. Balancing driving passes across different days of the week and times of each 24hour day, Aclima claims that its methodology provides for an efficient and effective strategy that statistically accounts for factors such as variations in weather, source emissions, and other atmospherically relevant variations (e.g., chemical processing and transport—movement of pollutants from one area to another). The mobile sensing platforms obtained more than 28 million, 1-second data points in the SBM community. Pollutants included particulate matter (PM2.5), black

California Asphalt Magazine • Environmental Issue

carbon (BC), carbon monoxide (CO), carbon dioxide (CO2), nitrogen oxide (NO), nitrogen dioxide (NO2), ozone (O3), methane (CH4), ethane (C2H6), and volatile organic compounds (VOCs). Aclima claims that the dataset provides the spatial resolution needed to evaluate the potential impacts of pollutants emitted from sources on sensitive and general populations from one block to the next. Diagnostic and platform variables including temperature, relative humidity, pressure, position (longitude, latitude), and car speed were also measured at 1 second but omitted from the report. INDICATORS Aclima developed the following four (4) Air Pollution Indicators that it says “qualitatively provide information on the strength of source types (e.g., heavy-duty diesel trucks, gasoline vehicles) … that are not designed to denote specific health outcomes, but may suggest a higher potential health risk, especially to sensitive individuals.” [emphasis added]: • Diesel Pollution Indicator (DPI) identifies diesel emissions based on NO2 and BC. “The DPI is based on these two components because emissions


from sources that use diesel fuel, like heavy-duty trucks, and train locomotives and drayage trucks found in railyards, contain a higher concentration of BC and NO2 than emissions from other combustion sources.”

Figure 2. Industrial Facilities

• Traffic Pollution Indicator (TPI) is based on concentrations of CO and CO2. “The small distinction between gasoline and diesel emissions is possible with these pollutants because gasoline engines emit a higher fraction of CO per unit of energy than diesel vehicles.” • Particulate Matter Indicator (PMI) is based on concentrations of PM2.5 “emitted directly from natural sources, such as windblown dust, and man-made sources, such as vehicles and industry, and it also can be formed by chemical reactions in the atmosphere. The latter can comprise a major fraction (>50%) of PM2.5.” • Methane Indicator (MI) reports the levels of methane from all sources but “elevated methane levels most likely reflect emissions from man-influenced sources such as natural gas infrastructure, landfills, livestock, and sewage. A potent greenhouse gas, methane has significant impacts on global climate change, and can pose local safety risks when associated with natural gas distribution leaks.” Air Pollution Indicators are defined as “High” and “Medium” representing the upper distribution of indicator associated measured pollutant(s) values at a road segment. Air Pollution Indicators are intended to aid in the identification of streets heavily impacted by traffic, such as heavy-duty diesel trucks, suggesting a higher level of diesel particulate emissions


Note: Screenshot showing industrial facilities as icons that may be clicked for more information. Facility types in green are those mentioned during Community Steering Committee meetings. Asphalt plants are omitted because they were not mentioned. Table 1. Comparison of Mobile and Stationary Monitoring Pollutant

PM 2.5 (µg/m3)

CO (ppm)

NO 2 (ppb)

O 3 (ppb)

BC (µg/m3)

AQMIS: Mean, Median, Maximum(1)

Aclima Hyperlocal: Mean, Median, Maximum(2)

(3)Mean: 12.9

Mean: 11.3

Median: 11.0

Median: 10.9

Max: 201.0

Max: 79.8

Mean: 0.3

Mean: 0.5

Median: 0.3

Median: 0.5

Max: 1.0

Max: 1.3

Mean: 18.4

Mean: 17.3

Median: 17.4

Median: 16.6

Min: 3.7

no data

Max: 46.4

Max: 42.6

Mean: 40.6

Mean: 32.1

Median: 32.1

Median: 32.3

Max: 142.8

Max: 45.1

Mean: 1.0

Mean: 1.7

Median: 0.9

Median: 1.6

Max: 3.4

Max: 4.6

(1) from E. 4th Street, except for PM 2.5. (2) for entire SBM - used segment median or BNMedian values, dependent on the pollutant. (3) values from the Riverside-Rubidoux SCAQMD regulatory site

at that location. The Indicators provide information that may assist communities in targeting specific stationary and mobile sources, such as heavy-duty diesel trucks, warehouses, factories, and railyards. These sources may have an adverse air quality impact on nearby residents and sensitive

sites, like schools, childcare, and medical facilities. The concern is other facilities, such as asphalt plants, may be swept up into this targeting. Currently, SCAQMD staff is reviewing the Alcima report to determine what additional actions may be warranted given the distribution of Indicators presented.

California Asphalt Magazine • 2022 Environmental Issue

Figure 3. PM 2.5 Aggregated Areas Exceeding the Regulatory Standard (12 µg/m 3)

Note: For PM 2.5, the EPA annual standard is 12 µg/m3 (averaged over 3 years) and 22% of the measurement area exceeds this value. Figure 4. Composition of PM 2.5

Source: SCAQMD Draft 2022 AQMP (Pg. II-2-41).

COMPARISON OF MOBILE TO STATIONARY MONITORING RESULTS All these measurements wouldn’t mean much if they were not shown to correlate with concentrations measured by SCAQMD at nearby monitoring stations that use U.S. Environmental

Protection Agency (EPA) default test methods. The report presents the average, median, and maximum concentrations of each pollutant during the study period (July 1, 2021 to Sept. 30, 2021) at the E. 4th Street regulatory site in San Bernardino and from Aclima mobile mapping throughout San Bernardino

California Asphalt Magazine • Environmental Issue

and Muscoy are presented in the table below. Table 1 shows that the mobile measurements are similar to the measurements at stationary monitoring stations operating by SCAQMD. Aclima aggregates measurements to larger areas searching for patterns of high pollution to assist community members in determining what actions to pursue that may reduce exposure. Values of a hexagon can be compared to the nearest EPA regulatory site measurements or to the level of EPA air pollution health standards. Areas emitting higher than area average greenhouse pollutants (CO2, CH4, and BC) can also be identified for further investigation or reductions. Figure 4 shows that the PM2.5 in SCAQMD is only about 10% directly emitted crustal materials as one would find from roads, stockpiles, and process equipment at a typical building materials manufacturing facility like an asphalt plant. More than 80% of PM2.5 is composed of organic matter, ammonium, nitrates, and sulfates formed secondarily from exhaust emissions in the atmosphere. The amount of noncrustal speciates in PM2.5 is even more pronounced during days with the greatest PM2.5 concentrations. DISCUSSION Aclima is undoubtedly committed to a science-based approach and lobbied hard during their presentation for users to submit feedback through the website, which they assured would be seriously considered and used to improve the service. Aclima’s website claims that “We engage in ongoing validation of our novel approaches through independent verification, publication, and cooperative research with leading research institutions. Examples include partnerships with the California Air Resources Board, UT Austin, Carnegie Mellon, Stanford, and


Lawrence Berkeley National Labs. Our groundbreaking peer-reviewed publications have introduced a new understanding of hyperlocal air pollution, exposure, and methods for data collection.” The website contains about fifteen (15) peer reviewed papers that the company says supports their technology. However, insufficient information is provided in the Alcima San Bernardino Muscoy Community Report for others to determine the validity of data and therefore reasonable peer scrutiny is not possible. As this information is being publicly funded and used to inform policy, it is of the utmost importance that scientific best practices are followed and that widely accepted procedures for peer review occur. In addition, the data visualizations lack important context. The following contextual items come to mind but there are sure to be many more: • Road surface material. Unpaved roads could cause higher PM2.5 to be measured by mobile monitors. • Geography of the road network is a necessary consideration when interpreting the data. For instance, pollutant concentrations near some stationary sources may be greater due to emissions from the facility. Alternatively, it may be that the road network is converging near the such a facility. • Topography and microclimates play a role. Figure 3 shows that the northern portion of SBM has greater PM2.5 concentrations than the southern portion. Those looking to blame may insist that there must be some source(s) in that area causing the PM2.5 to be greater. However, the truth may be that the air gets caught in the valley running north-south causing more stable conditions and retarding dispersion.


ALCIMA RESPONSE In the process of developing this article, and in the interest of transparency, we shared a draft with San Francisco-based Alcima. Company officials welcomed the scrutiny of their technology and data publishing platform. The official company response, provided by Director of Communications Sarah Cafasso on behalf of the company, is printed in its entirety below: “Aclima worked in partnership with our customer, the South Coast Air Quality Management District, and local community members in the production of the San Bernardino / Muscoy public report. When we work with customers who are air quality scientists and experts like South Coast AQMD, they often ask us to deliver our results in several different ways, including comprehensive technical reports as well as simplified, easier to understand public reports. At the request of South Coast AQMD and local community members, we designed the public report referenced in this article for a general audience, so that the community could learn more about the data collected by Aclima in their area and air quality issues more broadly. The goal was to make the issues easier to understand and provide some insights to community members — it is not designed for a research or professional audience, nor is it designed to be a comprehensive report of Aclima’s technical analyses in the area. “We are happy to work with colleagues in the research community to peer-review our data and we have partnerships with many academic and scientific institutions. For this San Bernardino / Muscoy public report, we worked (and continue to work) with the District’s community engagement specialists and with a subset of the District’s many scientific experts, some of whom have access to Aclima’s more comprehensive datasets through our professional software,

which allows them to independently analyze the data collected during the 2021 project period. In addition, Aclima’s methods and technology are publicly disclosed in our patents and in the growing number of peerreviewed research papers authored by our scientists.” “The San Bernardino / Muscoy interactive report was intended to be a starting point for users to review the data insights on their own and apply their own local knowledge, including, but certainly not limited to, contextual items such as road surface material, geography of the road network, topography, and microclimates. The contextual items that were mentioned in the public report may only represent a small percentage of the possible factors contributing to persistent air quality conditions in the area, as countless factors can contribute to local conditions over a three-month period. The report was informed by input from local residents about their concerns and what they were most interested in learning from the results. “We appreciate you taking the time to explore the interactive public report in great detail, as we hope you and others will continue to do. We’re also excited to expand our relationships with industrial partners and customers to support them with Aclima’s software and data solutions to assess environmental conditions around their facilities and support efforts to optimize operations. In addition, we’re constantly seeking to improve how we communicate our data insights and findings with the public. In all the communities where we operate, our goal is to provide people with a better understanding of typical air quality as they go about their lives.” CONCLUSION The obvious take-away from all of this should be fairly clear: If facility operators do not collect their own monitoring data, then they will be less able to influence

California Asphalt Magazine • 2022 Environmental Issue

the narrative about their facility. Regardless of whether monitoring is undertaken, each facility should have their own robust data, which can stand up to scientific scrutiny, to answer for pollution levels measured by Alcima or anyone else near their facilities. This is especially important if those levels are greater than in the surrounding areas. Meanwhile, CalAPA will continue to engage with air quality regulators about the proper use of “hyperlocal” air monitoring data. CA Scott D. Cohen, P.E., C.I.H., is a Principal Engineer with Sespe Consulting, a Trinity Consultants Company, and is Co-Chairman of the CalAPA Environmental Committee. Russell W. Snyder, CAE, executive director of the California Asphalt Pavement Association, contributed to this story.

References: California Air Resources Board “Criteria Pollutant and Toxics Emissions Reporting” informational web page (2022). Accessed Aug. 2, 2022: https:// criteria-and-toxics-reporting “San Bernardino, Muscoy Community Air Quality Report” website (2022). Accessed July 29, 2022: https:// “Look up air pollution and climate health information for any address in the Bay Area” website (2022). Accessed July 29, 2022: “AB 617 Community Steering Committee (CSC) Meeting for San Bernardino Muscoy” (2022). On-line meeting hosted by the South Coast Air Quality Management District on Feb. 10, 2022: watch/?v=678565489832994 “A Story Map: Air Monitoring Progress Update – San Bernardino, Muscoy Community” website (2022). Accessed July 29, 2022. https://

California Asphalt Magazine • Environmental Issue

MapJournal/index.html?appid=f8bbfa 504abc4081bdf2eb8fd70171d3 “Draft 2022 Air Quality Management Plan” website (2022). Accessed August 2, 2022. air-quality/clean-air-plans/air-qualitymgt-plan# Montalvo, M (2022) “Three resign in protest from San Joaquin Valley Air District group, calling it a ‘sham’”. The Fresno Bee newspaper, July 15, 2022. Cohen, S (2021) “Adventures in Air Quality Regulation and Health Risk Assessment.” California Asphalt, Journal of the Asphalt Pavement Association, Vol. 25, Issue 4, PP 18-20. Cohen, S. (2020) “Health Risk Assessment: What to Expect, How to Prepare.” California Asphalt, Journal of the California Asphalt Pavement Association, Vol. 24, Issue 4, PP 14-18. Cohen, S. (2017) “Environmental Justice and facility-related health risk scrutiny coming to a community near you.” California Asphalt, Journal of the California Asphalt Pavement Association, Vol. 23, Issue 4, PP 20-24.


Implementation of NOx limits on Asphalt Dryers through Rule 1147.1 begins in South Coast AQMD By Scott Taylor


he biggest overhaul in decades to air quality regulations covering asphalt plant burners in Southern California is taking effect this year. The process for development of Rule 1147.1 started in earnest in early 2017 when changes to Rule 1147 were first proposed. At that time the CalAPA Environmental Committee mobilized a working group to evaluate and meet with South Coast Air Quality Management District (SCAQMD) staff. For over four years there were numerous Working Group meetings, CalAPA meetings, and individual producer meetings with SCAQMD staff. Through the intense engagement It became apparent that the aggregate dryers that are a typical feature of asphalt plants had unique issues that required a separate rule. With decades of experience in aggregate dryers and rule development the CalAPA subcommittee supplied SCAQMD with data to help with the evaluation and analysis necessary for the rule development. The development process did not slow down even when COVID restrictions prevented in-person meetings and site visits. Working group meetings moved to a “virtual” ZOOM platform and members of the committee offered virtual tours of their facilities so staff could see the operation and the physical challenges that impeded some of the proposed NOx emission reduction strategies. A July 22, 2020 virtual plant tour was conducted by then-Environmental Manager Ken Barker of CalAPA member Sully-Miller/Blue Diamond Materials, and was well-received by regulators. The collaborative effort with SCAQMD allowed for productive discussions about feasibility of proposed limits and realistic solutions to reduced emissions for aggregate dryers. These efforts had a significant impact in the final rule language. The result is Rule 1147.1 which was adopted by the SCAQMD board on August 6, 2021. The rule targets a


NOx limit of 30 PPM measured at 3% O2 and a simultaneous limit for CO of 1000 PPM at 3% O2. For NOx this is 25% reduction from the current Rule 1147 limit. For CO the reduction is even greater as it achieves a 50% reduction from current rule requirements. For some RECLAIM facilities (“Regional Clean Air Incentives Market” program) the reduction is even greater. RECLAIM plants have had the option to offset emissions with credits which has allowed their current burner to remain in operation. For some of these facilities the reduction in NOx will be as much as 70%. These reductions will require a variety of solutions that will vary from site to site. Meeting the NOx and CO requirements requires significant lead time for capital procurement, equipment redesign and installation depending on the plant, the burner and the age of the equipment. Regardless, the phase-in schedule for implementation is aggressive. As of July 1, 2022, all facilities which have a burner installed before Jan. 1, 2010 and have a NOx limit that are greater than 40 PPM were to submit an application by July 1, 2022. This has placed a demanding schedule for the past 13 months on facilities to evaluate and prepare for their facilities to make the change if they are in the first wave. Once approved, the facilities will have a short 18 months from the issuance of the “Permit To Construct” (PTC) to demonstrate compliance with the standard. As supply chain issues continue to push out lead times for parts and burners, meeting the timeline will require careful planning. The second phase will require burners with limits above 40 PPM NOx that were installed after Jan. 1, 2010 to submit an application by July 1st of the year the burner reaches 12 years of age. These facilities will also have 18 months to demonstrate compliance with the PTC conditions. The rule implementation schedule will continue until all burners

on aggregate drying facilities in an asphalt plant can meet the 30 PPM NOx and 1000 PPM CO requirements. Currently many facilities perform only initial compliance tests on their burners. RECLAIM facilities are more accustomed to regular compliance tests as many of them are required to perform either annual or triennial testing. Rule 1147.1 requires an initial compliance demonstration and annual testing thereafter. Once a facility is subject to the new limit the initial compliance demonstration must be performed and annual testing must be maintained. Rule 1147.1 is the most significant change to asphalt plant dryer burners since the adoption of the REClAIM program in 1993. After four years of workshops and meetings to develop the rule, the first applications have been submitted for processing. Now the plants are turning their efforts to modifying the plants and demonstrating compliance. Through the joint efforts of the CalAPA Environmental Committee, AQMD staff and other stakeholders, the approved Rule 1147.1 achieves the aggressive reductions demanded by AQMD and provides more clarity to asphalt dryers emission requirements in Southern California. CA Scott Taylor is president of Taylor Environmental Services, Inc. and is Co-Chairman of the CalAPA Environmental Committee.

References: Taylor, S. (2021) “South Coast AQMD to consider NOx reduction rule for aggregate dryers.” California Asphalt, Journal of the California Asphalt Pavement Association. Vol. 25, Issue 4 (PP 26-27) Snyder, R (2020) “State & local air quality regulators tour asphalt plants to get an up-close view of operations, environmental controls.” California Asphalt, Journal of the California Asphalt Pavement Association. Vol. 24, Issue 4 (PP 8-11)

California Asphalt Magazine • 2022 Environmental Issue


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